(Conspiracy To Acquire And Transfer Anti-Aircraft Missiles)
The Grand Jury charges:
2. It was a part and an object of the conspiracy that REZA OLANGIAN, a/k/a "Raymond Avancian," a/k/a "Ray," the defendant, a United States national, and others known and unknown, knowingly and willfully would and did produce, construct, otherwise acquire, transfer directly and indirectly, receive, posses, import, and use (1) an explosive and incendiary rocket and missile that is guided by any system designed to enable the rocket or missile to seek and proceed toward energy radiated and reflected from an aircraft and toward an image locating an aircraft, and otherwise direct and guide the rocket and missile to an aircraft; (2) a device designed and intended to launch and guide said rocket and missile; and (3) a part and combination of parts designed and redesigned for use in assembling and fabricating said rocket, missile, and device; to wit, OLANGIAN agreed to acquire and transfer surface-to-air missile systems for the purpose of conveying them to Iran, in violation of Title 18, United States Code, Section 2332g.
3. In furtherance of the conspiracy and to effect the illegal object thereof, REZA OLANGIAN, a/k/a "Raymond Avancian," a/k/a "Ray," the defendant, and others known and unknown, committed the following overt acts, among others:
a. On or about August 17, 2012, OLANGIAN, who was then in Iran, participated in a live videoconference with a confidential source acting at the direction of the United States Drug Enforcement Administration ("DEA") and purporting to be a weapons and aircraft broker (the "CS"), during which conference OLANGIAN and the CS discussed, among other things, the sale to OLANGIAN of IGLA-S missile systems, and the CS showed OLANGIAN an IGLA-S missile system, which OLANGIAN inspected.
b. On or about August 25, 2012, OLANGIAN and the CS spoke by telephone and discussed, among other things, details regarding the inspection of the IGLA-S missile systems requested by OLANGIAN and the prices and method of payment for those items.
c. On or about September 6, 2012, OLANGIAN sent an e-mail to the CS, asking the CS, among other things, to send OLANGIAN a photograph of the IGLA-S missile that the CS had displayed during the August 17, 2012 teleconference, as described in subparagraph (a) above.